Williams v. Reed

604 U.S. 168 (2025) Supreme Court of the United States 2025-02-21

civil; unemployment claimants sued the state labor secretary in Alabama state court under § 1983 for an order to speed up processing of their benefits claims; trial court dismissed for failure to exhaust state administrative remedies; Alabama Supreme Court affirmed; certiorari granted; reversed and remanded (5-4) (result: remanded)

Facts

  1. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    But according to Bateman, the Department never scheduled a hearing or otherwise acted on his appeal, even after he attempted to follow up by email and phone calls numerous times.
  2. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    The claimants did not ask the court to rule that they were entitled to unemployment benefts.
  3. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    In the unusual circumstances presented here— where a state court's application of a state exhaustion re- quirement in effect immunizes state offcials from § 1983 claims challenging delays in the administrative process— state courts may not deny those § 1983 claims on failure-to- exhaust grounds.
  4. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    This Court has long held that “a state law that immunizes government conduct otherwise subject to suit under § 1983 is pre-empted, even where the federal civil rights litigation takes place in state court.”
  5. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    Rather, a state rule runs afoul of Hay- wood if it operates as an “immunity statute cloaked in juris- dictional garb” by wholly barring a “particular species” of § 1983 suits in state court.
  6. 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
    By affording immunity from those claims, the Ala- bama ruling contravenes this Court's § 1983 precedents.